1. Introduction

MAKATOUNAKIS LTD is firmly committed to creating and maintaining a working environment in which all employees and business partners are treated with dignity, courtesy, and respect. The Company’s workplace shall be characterized by mutual trust and be free from intimidation, oppression, and exploitation. MAKATOUNAKIS LTD does not tolerate any form of unlawful discrimination or harassment against any employee, customer, or business partner. Through this Policy, the Company declares its firm and non-negotiable commitment to the prompt and effective prevention and handling of every incident of violence and/or harassment in the workplace.

2. Scope

MAKATOUNAKIS LTD complies with all measures and obligations relating to the implementation of the provisions of Part II of Law 4808/2021 concerning the prevention and elimination of all forms of violence and harassment, including gender-based violence, gender-based harassment, and sexual harassment.

This Policy is adopted in accordance with Articles 9 and 10 of Law 4808/2021 and the relevant implementing legislation. It applies to all persons referred to in Article 3(1) of Law 4808/2021, namely all employees regardless of the type of employment contract or working relationship, as well as third parties interacting with the Company, including customers, business partners, and suppliers.

MAKATOUNAKIS LTD recognizes and respects every employee’s right to work in an environment free from violence and harassment and does not tolerate any such conduct, in any form, by any person, including employees, business partners, customers, suppliers, or visitors, whether such conduct occurs during work, is work-related, or arises out of work.

This Policy applies to all persons working for or on behalf of the Company regardless of their contractual status, including employees engaged under project contracts, independent service agreements, contracts of mandate, personnel supplied through third-party service providers, trainees, apprentices, interns, volunteers, former employees, and job applicants.

3. Purpose

The purpose of this Policy is to establish and maintain a working environment that respects, promotes, and safeguards human dignity and every individual’s right to a workplace free from violence and harassment. MAKATOUNAKIS LTD recognizes and respects every employee’s right to work in an environment free from violence and harassment and does not tolerate such conduct in any form or by any person. Furthermore, this Policy establishes the Company’s procedures for receiving, handling, and investigating complaints concerning incidents of workplace violence and harassment.

4. Zero Tolerance Statement

MAKATOUNAKIS LTD is committed to maintaining a safe, respectful, and modern working environment in which all employees and business partners are treated with respect, equality, and professionalism.

The Company applies a zero-tolerance policy towards every form of violence, harassment, bullying, or discriminatory treatment, including sexual harassment, regardless of the manner in which such conduct is manifested or the person from whom it originates.

This commitment applies to everyone who works for or cooperates with the Company, regardless of the nature of their employment or contractual relationship, as well as job applicants, interns, external associates, suppliers, customers, and visitors, in connection with any work-related activity.

MAKATOUNAKIS LTD is committed to:

• Preventing and eliminating every incident of violence or harassment.

• Receiving, examining, and investigating every relevant report objectively, impartially, confidentially, and with respect for all parties involved.

• Protecting individuals who report incidents or assist in investigations from any form of retaliation or adverse treatment.

• Taking appropriate administrative or disciplinary measures whenever a violation of this Policy is established, in accordance with applicable legislation and the Company’s internal regulations.

All employees, members of Management, and the Company’s business partners share responsibility for creating and maintaining a working environment that promotes mutual respect, dignity, equal treatment, and cooperation.

MAKATOUNAKIS LTD considers the protection of human dignity and the maintenance of a workplace free from violence and harassment to be fundamental prerequisites for its effective operation, the development of its people, and the delivery of high-quality services to its customers and business partners.

5. Definitions

For the purposes of this Policy, the following definitions shall apply:

5.1. Workplace Violence and Harassment

Workplace violence and harassment refer to any form of conduct, act, practice, or threat of such conduct, whether occurring as a single incident or repeatedly, that has the purpose or effect of causing, or is likely to cause, physical, psychological, sexual, or economic harm to the person concerned.

Violence and harassment are not tolerated regardless of the relationship between the parties involved or whether the conduct originates from an employee, supervisor, member of Management, business partner, supplier, customer, or any other person associated with the Company.

5.2. Harassment

Harassment is defined as any unwanted conduct that has the purpose or effect of violating a person’s dignity and creating an intimidating, hostile, degrading, humiliating, or offensive working environment, regardless of whether such conduct constitutes a form of discrimination.

Harassment may be verbal, non-verbal, physical, psychological, or electronic, including through email, instant messaging applications, or social media platforms.

5.3. Gender-Based Harassment and Sexual Harassment

Gender-based harassment refers to any form of conduct related to a person’s gender that has the purpose or effect of violating that person’s dignity and creating an intimidating, hostile, degrading, humiliating, or offensive environment.

This definition also includes sexual harassment, namely any unwanted verbal, non-verbal, or physical conduct of a sexual nature, including unwelcome comments, insinuations, gestures, propositions, physical contact, or any other conduct that violates the dignity of the recipient.

5.4. Workplace

For the purposes of this Policy, the workplace includes any location or circumstance in which work is performed or that is related to work, including but not limited to:

• The Company’s premises.

• Customer premises where professional duties are performed.

• Business meetings and professional visits.

• Business travel and training activities.

• Corporate events and company activities.

• Work-related travel and transportation.

• Communications conducted via telephone, email, messaging applications, or other information and communication technologies.

• Any other circumstance directly or indirectly connected with work.

5.5. Indicative Forms of Violence and Harassment

The following behaviours are considered prohibited, including but not limited to:

• Abusive or offensive language.

• Verbal or physical threats.

• Humiliating or degrading behaviour.

• Repeated and unjustified criticism intended to undermine an employee.

• Systematic exclusion from meetings or teamwork.

• Spreading malicious comments or rumours.

• Cyberbullying or harassment through electronic means.

• Unwanted touching, gestures, or physical contact.

• Sexual comments, insinuations, or propositions.

• Sending offensive, obscene, or sexually explicit content through electronic communication.

• Promising or threatening career advancement or employment-related benefits in exchange for the acceptance of sexual conduct.

• Any form of retaliation, intimidation, or victimization against a person for submitting a complaint or participating in the investigation of an incident.

The above examples are indicative only and do not limit the definition of violence and harassment.

5.6. Conduct That Does Not Constitute Violence or Harassment

The following actions, when carried out as part of the reasonable exercise of managerial authority and the proper operation of the Company, shall not be considered violence or harassment:

• Assigning duties and setting work priorities.

• Evaluating performance and providing constructive feedback.

• Giving comments or instructions aimed at improving work performance.

• Applying reasonable deadlines and work procedures.

• Taking disciplinary or organizational measures based on objective and lawful criteria.

• Professional disagreements expressed respectfully and without offensive, intimidating, or abusive behaviour.

MAKATOUNAKIS LTD assesses every report objectively, taking into account the actual circumstances of each case, in order to safeguard the dignity of all parties involved and ensure the proper implementation of this Policy.

6. Rights and Responsibilities

The Company recognizes the right of every employee to work in a safe, healthy, and respectful environment where mutual respect, equal treatment, cooperation, and professional conduct prevail. Every employee has the right to be protected from any form of violence, harassment, or discriminatory treatment and to report or file a complaint without fear of retaliation or adverse consequences.

At the same time, all employees, regardless of their position or employment status, are required to treat colleagues, business partners, customers, and every individual interacting with the Company with respect, actively contributing to the maintenance of a workplace free from violence and harassment. Every employee is expected to refrain from any prohibited conduct, report incidents that come to their attention, and cooperate in good faith during the investigation of any relevant reports.

Management and supervisory personnel bear increased responsibility for implementing this Policy. They are expected to act as role models of professional conduct, identify at an early stage any behaviour that could lead to incidents of violence or harassment, handle every report objectively, impartially, and confidentially, and take all necessary measures to protect those involved and restore a respectful working environment.

7. Prevention and Elimination of Workplace Violence and Harassment

7.1. Violence and Harassment Risk Assessment

MAKATOUNAKIS LTD recognizes that violence and harassment may affect the health, safety, and well-being of employees, as well as the effective operation of the business. For this reason, the Company periodically evaluates factors that may create or contribute to such incidents and implements appropriate preventive measures.

The assessment takes into consideration, among other factors:

• The organization of work and the allocation of responsibilities.

• Working relationships between employees and supervisors.

• Communication with customers, suppliers, and external business partners.

• The potential for verbal or psychological violence during service delivery.

• Psychosocial risks associated with workload, deadlines, and working conditions.

• Any other factor that may affect the dignity or safety of employees.

7.2. Prevention and Protection Measures

The Company implements all reasonable organizational and administrative measures to prevent and address incidents of violence and harassment, including:

• Assessing factors that may create or contribute to incidents of violence or harassment, taking into account the nature of the work, work organization, and workplace conditions.

• Incorporating relevant psychosocial risks into occupational risk assessments, where appropriate, and implementing suitable preventive measures.

• Informing and raising employee awareness regarding this Policy, the various forms of violence and harassment, their rights and responsibilities, and the available reporting procedures.

• Identifying and addressing at an early stage behaviours that may lead to incidents of violence or harassment.

• Promoting open communication, cooperation, mutual respect, and equal treatment as fundamental principles of the Company’s corporate culture.

• Encouraging the timely reporting of incidents or behaviours that may lead to violence or harassment while ensuring confidentiality and protecting individuals acting in good faith.

The Company periodically reviews the effectiveness of these measures and implements any necessary improvements in order to continuously strengthen a working environment that promotes dignity, safety, and respect for all employees and business partners.

8. Employee Information and Awareness

The Company’s employees receive appropriate information and training to ensure they fully understand the adverse effects of violence and harassment, their rights and responsibilities under this Policy, and the Company’s procedures for reporting such incidents.

Management encourages open communication and employee participation in creating a safe and supportive working environment by promoting prevention through awareness, cooperation, and the continuous improvement of internal procedures.

9. Reporting and Investigation Procedure

Any employee or other person falling within the scope of this Policy has the right to report any incident of violence or harassment that they believe they have experienced or witnessed during the course of, or in connection with, their work.

A complaint may be submitted where a person:

• Has been subjected to any form of violence or harassment.

• Has witnessed an incident of violence or harassment.

• Believes they have been subjected to retaliation or adverse treatment as a result of submitting a complaint or participating in the investigation of an incident.

Complaints may be submitted to the designated Reporting Officer by completing the Workplace Violence and Harassment Report Form, which is available in printed form at all Company premises and electronically (distributed to all employees via email), or through any other appropriate reporting channel provided by the Company.

Any employee or third party involved in the workplace may submit a complaint or report:

• Verbally or in writing to the designated Reporting Officer.

• By email at [email protected].

• In writing, in a sealed envelope addressed to the Reporting Officer or to the Company’s legal representative.

• Externally, to the Labour Inspectorate, the Greek Ombudsman, or the competent judicial authorities, irrespective of the Company’s internal reporting procedure.

The Reporting Officer shall acknowledge receipt of every complaint within five (5) working days of its submission and shall inform the complainant of the procedure that will be followed.

Ms. Savvina Makatounaki has been appointed as the Company’s Reporting Officer.

To the extent possible, every report should include the complainant’s details, a description of the incident, the date, time, and location of its occurrence, together with any additional information or supporting evidence that may assist in its investigation.

The Company is committed to:

• Receiving and examining every complaint objectively, impartially, and without undue delay.

• Ensuring the confidentiality of the procedure and the protection of the personal data of all parties involved.

• Taking all necessary measures to protect the complainant, witnesses, and any person cooperating in the investigation.

• Prohibiting any form of retaliation, intimidation, or adverse treatment against any individual who submits a complaint in good faith or participates in the investigation process.

Where an investigation confirms a breach of this Policy, the Company shall take appropriate corrective and disciplinary measures in accordance with applicable legislation and its internal regulations.

Support for Victims

The Company informs employees that, in addition to the internal procedures established by this Policy, they have the right to seek assistance from the competent administrative, judicial, or other public authorities for the protection of their rights, in accordance with applicable legislation.

Protection and Support for Employees Who Are Victims of Domestic Violence

Where reasonably practicable, the Company shall implement measures to support employees who are victims of domestic violence, including flexible working arrangements, changes to their work location or position, and assistance in accessing support services (such as the National Helpline 15900). Every related request shall be handled with confidentiality, sensitivity, and respect.

9.1. Investigation and Review of Reports

Every complaint or report shall be examined promptly, impartially, and confidentially. During the investigation:

• The confidentiality of the complainant’s and the respondent’s personal information shall be safeguarded.

• Personal data shall be processed exclusively for the purposes of the investigation and in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and Law 4624/2019.

• Both parties involved shall be given the opportunity to be heard, in accordance with the principle of the right to be heard.

• The investigation shall be completed within a reasonable period of time, generally within thirty (30) calendar days from the acknowledgement of receipt of the complaint, unless an extension is required due to the complexity of the case.

10. Protection Against Retaliation

MAKATOUNAKIS LTD ensures that every person who, in good faith, submits a complaint or participates in the investigation of an incident of workplace violence or harassment is protected against any form of retaliation, intimidation, adverse treatment, or discrimination.

Any action intended to pressure, disadvantage, or penalize an employee because of their participation in an investigation or because they have exercised their rights under this Policy is strictly prohibited and shall be treated as a serious violation of the Company’s rules.

Any form of direct or indirect retaliation against an employee who has submitted a complaint or report, or who has participated in any way in the investigation process, is strictly prohibited. Retaliatory conduct constitutes a violation of this Policy and is subject to the sanctions provided for under Article 13 of Law 4808/2021.

11. Confirmation of Violations

Where an investigation confirms a violation of this Policy, the Company shall immediately take the appropriate corrective and disciplinary measures, depending on the severity of the violation, including:

• Verbal or written warning.

• Transfer of the offender to another department or position.

• Termination of the employment relationship in accordance with applicable labour legislation.

• Referral to the competent authorities where required by law.

The above measures shall apply without prejudice to any criminal or civil liability that may arise.

12. Sanctions

Violations of this Policy shall be treated with the utmost seriousness and shall result in the implementation of appropriate measures, depending on the nature, severity, and consequences of the incident.

The Company may issue recommendations, written warnings, organizational or disciplinary measures, or, where appropriate, terminate the employment or business relationship in accordance with applicable labour legislation and the Company’s internal regulations. Where the facts constitute a breach of criminal or other applicable legislation, the Company shall cooperate fully with the competent administrative and judicial authorities.

13. Malicious Complaints

Complaints that are proven to be manifestly malicious shall be considered inadmissible and may themselves be investigated in order to determine the motives involved and to restore order through lawful procedures.

14. Monitoring and Review of the Policy

This Policy forms an integral part of the corporate governance framework of MAKATOUNAKIS LTD and applies to all employees and business partners of the Company.

Management monitors the implementation of this Policy, periodically evaluates its effectiveness, and reviews it whenever necessary due to legislative changes, organizational requirements, or the adoption of best practices. The Company’s objective is to continuously ensure a working environment that promotes dignity, safety, trust, and mutual respect.